Germany is leading in the EU with the number of MiCA licenses issued. The country also has the most Bitcoin nodes of all European countries.
Large banks such as Deutsche Bank, DZ Bank, and Commerzbank have all entered the crypto market under the new regulatory framework.
The official image versus reality
On paper, the figures look strong. But people in the sector experience the situation differently. Despite the success statistics, activity and talent are flowing to other European countries.
The difference between the official figures and what is actually happening points to a structural problem that jeopardizes the long-term position as a hub.
More than 30 crypto licenses have been granted, more than almost any other EU country. Luxembourg only approved three.
On paper, Germany thus seems to be clearly winning. But most licenses have gone to traditional banks with limited services. Startups and crypto-native companies working on new digital infrastructure are obtaining their licenses elsewhere and still offering their services in Germany through alternative means.
Germany added sixteen new MiCA-licensed institutions in Q4 2025, but that figure hides a worrying trend. Most of them are banks that only offer one service, such as order execution or transferring money. This limited focus raises questions about the kind of crypto market Germany is building: a market dominated by established players and less by innovation.
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Berlin and Frankfurt are losing ground
During the BeInCrypto expert council on MiCA and crypto regulation, Matthias Steger, tax advisor for crypto and actively involved with the German Ministry of Finance on digital assets, was very clear about the situation.
“We have lost our major hubs in Berlin and Frankfurt,” said Steger. “And I think that's not because of MiCA itself. It's about how we Germans deal with the MiCA rules.”
This statement summarizes the core problem well. Germany applies the MiCA rules more strictly than almost any other EU country. This causes companies to seek refuge in cities like Vienna, Lisbon, and other countries where the process is faster and smoother.
Talking pro-crypto, but applying the strictest rules in the EU creates a mismatch, causing companies to leave.
MiCA will be fully in force in the EU from December 2024. Almost all EU countries gave companies 18 months to switch. Germany shortened that period to 12 months, with a hard deadline of December 31, 2025, for all crypto service providers to obtain a CASP license from BaFin. This tight timeline creates extra pressure, especially for companies that already find it difficult to comply with the rules.
The Austrian financial regulator positions itself as one of the most accessible MiCA authorities in the EU. The advantage is clear: quick licensing procedures of less than six months, while it takes much longer in Germany. In Vienna, there is clear regulation without the heavy bureaucracy that companies experience in Germany.
The results are visible and important. Bybit opened its European headquarters in Vienna after receiving a MiCA license from the FMA and wants to hire more than 100 people.
KuCoin chose Austria as the base for its EU regulations. The Swiss digital asset bank AMINA opted for Vienna and thus not for Frankfurt or Berlin, which is notable given Germany's strong banking world.
Steger sees the broader shift:
“In Austria, it is really well organized. In Portugal too. Some places, like Germany, are pro-crypto.” The wording is important. Germany is still seen as pro-crypto. But when practice shows something different, competitors seize their chance.
Steger made a clear recommendation:
“I would like to ask BaFin to lower the level. MiCA should be the minimum level, not the highest level as people think in Germany.”
This is the opinion of many people in the sector. Germany has the infrastructure, strong institutions, and official credibility. It has the most Bitcoin nodes in Europe. It has good banking relationships and financial expertise. However, whether the country retains the companies that want to build on that is still in question.